Responding to published concerns by the Federal Communications Commission (FCC) that captioned telephone services (CTS) are being utilized by people who are not appropriate candidates—leading to potential funding deficits of this critical service—the American Academy of Audiology (AAA) and the American Speech-Language-Hearing Association (ASHA) announced that the two audiology organizations have jointly developed proposed best practices for determining eligibility for the program.

CTS are designed to help people with hearing loss place and receive telephone calls by allowing them to speak directly to the called party and then listen and concurrently read captions of what the other party is saying. These vital services are paid for by the Telecommunications Relay Service (TRS) Fund and administered by the Federal Communications Commission (FCC).

Under the Americans with Disabilities Act (ADA), CTS is offered free of charge to people who are deaf or hard of hearing. However, FCC regulations prohibit the use of CTS by people who do not have a hearing loss, including those with no hearing loss who reside in the same household as the person with hearing loss, as well as people with hearing loss whose hearing loss is adequately addressed by other amplification or services. The use of CTS by individuals who have the capability of using conventional phone systems unnecessarily increases the cost of providing the TRS programs.

“The challenges associated with using the phone can contribute to isolating people with hearing loss, as well as negatively impacting educational opportunities, employment, and safety,” said ASHA 2019 President Shari Robertson, PhD. “This underscores the critical need to protect Captioned Telephone Services for those who truly need it. As such, ASHA is very pleased to collaborate with the American Academy of Audiology on these best practices, which will provide guidance to the members of our respective organizations as they care for their clients and patients.”

“Audiologists play a vital role in evaluating and treating hearing loss to ensure that our patients can continue to work, go to school, or interact with family and friends at home,” said AAA President Lisa Christensen, AuD. “As the expert on hearing loss and inner ear disorders, the audiologist is most qualified to evaluate whether a patient would be an ideal candidate for a captioned telephone. These best practices should serve as guidance to audiologists when determining the effectiveness of a captioned telephone for a certain patient. We thank ASHA for collaborating so effectively in developing these suggested best practices and look forward to continuing this work as the FCC continues to evaluate the CTS program.”

Nine suggested best practices are presented by the groups in this document. Among them are the following:

  • Individuals seeking CTS should have communication impairment that significantly affects speech understanding, even when using amplification devices and a conventional phone.
  • Individuals being considered for CTS should undergo an appropriate, comprehensive assessment to determine the need for assistive communication technologies, including CTS.
  • The patient history should include questions designed to determine the disability associated with telephone use and the availability of existing telephone technologies (e.g., smartphone, visual communication options such as FaceTime, availability of amplified systems, etc.), and desired patient outcomes.

The suggested best practices are intended to cover both analog and Internet-provided phone captioning. Analog CTS is landline based, available over conventional phone lines. The Internet Protocol Captioned Telephone Service (IP CTS) is an Internet-based system that uses an existing voice telephone and a computer—or other Internet-connected device—rather than the conventional phone network to provide the link and captions between the individuals who are deaf or hard of hearing and another party. It can also be used as an app with a smartphone. In 2007, the IP CTS was approved by the FCC as a form of relay service that may be compensated from the Interstate TRS Fund.

AAA and ASHA note that the organizations “support the availability of the CTS, including the IP CTS, to allow individuals who have the degree, type, or configuration that prevents traditional telephone use, to still be able to access telephone services. These same organizations also understand the necessity to restrict this service only to persons who are deaf or hard of hearing and support efforts to reduce the use of the service by those who do not have hearing loss in order to preserve the service.”

The complete suggested best practices are available here.

FCCFCC continues to look for ways to reduce costs in TRS Fund. Captioned telephone services are extremely important in meeting the communication needs of people with hearing loss, and it is well known that telephone use for those with hearing loss, including those with hearing aids and implantable devices, can be very difficult or impossible.

However, the FCC has been looking for ways to improve the efficiency and reduce costs related to IP CTS. TRS now represents almost 80% of the total minutes compensated by the FCC’s funding for the program, and the Commission reports that it is taking steps and explore ways to reduce waste of the TRS Fund and expand the Fund’s contribution base to ensure the continued viability of IP CTS for people with hearing loss who need it.

In July 2018, it proposed automating phone captioning, indicating an interest in utilizing automated speech recognition (ASR) as an alternative to live captioning assistants (CAs) for Internet Protocol Captioned Telephone Service (IP CTS), making the use of CAs optional.

On February 14, the FCC announced it was integrating IP CTS into the TRS User Registration Database, a centralized system of records currently used in the Video Relay Service (VRS) program.  The Commission says including IP CTS user registrations in this database would help it verify the identity of IP CTS users, audit and review IP CTS provider practices, and substantiate provider compensation requests.  In addition, the Commission proposed requiring IP CTS providers to add user account identifiers to call records submitted for compensation with the intent to combat misuse of funds and ensure money is used appropriately to support hard-of-hearing Americans.

The Commission also proposed simplifying the handling of 911 calls by no longer requiring IP CTS providers to serve as an unnecessary intermediary in connecting 911 call centers and IP CTS users.  If a mobile and web-based IP CTS user has a telephone number that enables the delivery of captions when an emergency dispatcher needs to reconnect a disconnected call, the Commission is proposing to relieve the IP CTS provider of the need to involve its captioning assistants in reconnecting such calls and to transmit additional data such as an ID and callback number for the person providing captions.